With the passage of the Telecommunications Act (“the Act”) of 1996, incumbent local exchange carriers (ILECs) must provide to a requesting competitive local exchange carrier” (CLEC) nondiscriminatory access to network elements on an unbundled basis and allow the CLEC to combine such network elements in order to provide telecommunications service. ILECs also have a duty to provide to CLECs interconnection with their network for the transmission and routing of telephone exchange service and exchange access. The interconnection contemplated by the Act provides nondiscriminatory access or interconnection to such services or information as are necessary to allow the requesting CLEC to implement local dialing parity, including nondiscriminatory access to telephone numbers, operator service, directory assistance, and directory listing, with no unreasonable dialing delays.
The increasing popularity of high speed data (HSD) over cable and the emergence of voice over IP (VoIP) technology as a viable alternative to the public switched network (PSTN) has provided cable operators an opportunity to offer a full range of VoIP-based telephony services that include custom features and advanced intelligent network services that rival the ILECs. While CLECs are allowed to compete to provide telephone services, the ILECs maintain control of certain elements of the telephone system. In particular, the ILECs define the rate centers that are used for billing and other purposes.
The North American Numbering Plan (NANP), on which all U.S. telephone numbers are currently based, is an integrated telephone numbering plan serving nineteen North American countries that share its resources. The NANP is administered by a North American Numbering Plan Administrator (NANPA). NANP numbers are ten-digit numbers consisting of a three-digit Numbering Plan Area (NPA) code, commonly called an area code, followed by a three digit central office code, also known as exchanges or prefixes, and a four-digit local, or line, number. The format is usually represented as NPA-NXX-XXXX where N is any digit from 2 through 9 and X is any digit from 0 through 9. Each area code is divided geographically into rate centers. A rate center is a geographically specified area that defines where a calling party is calling from and the location where the call is directed to for billing purposes. Each NXX prefix is uniquely associated with a rate center. Thus, a calling party will be billed based on the distance between the rate center associated with the calling party's prefix and the rate center associated with the called party's prefix.
Rate centers are a holdover from the days when a separate switch was needed for almost every community, and so calls between communities—even within a LATA—were “rated” as toll calls. When each rate center corresponded to a discrete switch, every rate center/switch needed its own NXX. But now, a single Class 5 typically serves multiple rate centers. By way of illustration in Maine, 133 rate centers are served by 15 host switches and 13 smaller switches.
Despite the technological realities, the rate center concept still determines the numbering scheme of the wired telephone system. Currently, two different rate centers served out of the same Class 5 switch must each have their own NXX, no matter how few lines each represents. The reason is that the prefix designates the local switching equipment. When a call is placed to NPA-NXX-XXXX, the telephone network examines the area code and prefix in order to route the call to the correct switch. The far-end switch then selects the correct line based on the line number. Because carriers do not typically share a local switch, each prefix must designate the wire center, the location of the switch and the carrier.
Typically, an ILEC selects rate center boundaries which define the geographic borders of the coverage area for each rate center. These boundary sets can be used along with mapping information to determine where in the rate center coverage area a particular phone number (and its associated residence) reside. ILECs have built their existing telephone systems and established central offices (COPs) to service the various rate centers. Therefore, the ILEC can readily determine the rate center associated with a particular number.
A CLEC does not have access to the central office information of the ILEC and thus must resort to mapping geographic phone data to boundary information to determine rate centers. At the edge of these boundary areas it is often difficult to accurately determine on which side of the boundary a particular number falls due to inaccuracies in defining the boundaries or improperly mapping the geographic location of the phone number and associated building.
For CLECs, this inaccuracy may cause new customer orders to be rejected because the new customer is associated with the wrong rate center. Rejected orders cost the CLEC time and money by delaying its ability to provide services to a customer.